Justia Virginia Supreme Court Opinion Summaries

In this case, the defendant was found guilty by a jury of second-degree murder, maliciously shooting at an occupied vehicle, and use of a firearm in the commission of murder, all arising from the shooting death of an individual in a parking lot. The prosecution conceded that the defendant did not personally fire the weapon, but argued that he was liable as a principal in the second degree, alleging that he knowingly assisted the unidentified shooter by providing access to his wife’s car, which was used in the attack. Evidence included surveillance footage, cell phone data placing the defendant near the scene, and statements made by the victim implicating a “brother,” a term the victim used for the defendant.The Circuit Court of the City of Roanoke denied the defendant’s motions to strike for insufficient evidence and, after a jury trial, convicted him. The defendant appealed to the Court of Appeals of Virginia, which unanimously vacated the convictions. The appellate court determined the evidence did not sufficiently establish that the defendant shared the shooter’s criminal intent or that he knowingly assisted in the crime, relying on precedent and emphasizing the lack of direct evidence of intent or motive.Upon further appeal, the Supreme Court of Virginia reviewed the record and found that the Court of Appeals misapplied the standard of review for sufficiency of the evidence in criminal cases. The Supreme Court held that, when viewed in the light most favorable to the prosecution, the circumstantial evidence admitted at trial was sufficient for a rational jury to conclude that the defendant knowingly assisted the shooter and shared criminal intent. The Supreme Court reversed the judgment of the Court of Appeals and reinstated the convictions and sentence imposed by the circuit court. View "Commonwealth v. Mahoney" on Justia Law

A church founded in 1982 primarily serving Korean-speaking congregants operated independently for many years, later joining a regional Korean-American presbytery affiliated with a national Presbyterian denomination. Over two decades, the church participated in various activities with the presbytery, including meetings, reports, dues, and ordinations, while maintaining autonomy in its financial and property matters. Disagreements arose when the presbytery asserted a trust interest in the church’s property after the church refinanced a loan without presbytery approval, referencing denominational rules requiring property to be held in trust for the national denomination. The church disputed its membership status and the applicability of those rules, asserting independence.After a failed ecclesiastical complaint with the synod overseeing the presbytery, the church filed suit in the Fairfax County Circuit Court seeking declaratory and injunctive relief regarding its independence and property rights. The presbytery counterclaimed, seeking a declaration of membership and property trust obligations. Both parties moved for summary judgment. The circuit court granted summary judgment for the church, finding it was not a member of the national denomination due to the absence of a covenant required by denominational rules, and thus, no trust obligation existed. The presbytery appealed.The Court of Appeals of Virginia reversed, holding that the circuit court lacked jurisdiction under the ecclesiastical abstention doctrine because the dispute involved church membership—a matter the parties had initially submitted to the synod.The Supreme Court of Virginia reviewed the case, holding that summary judgment was inappropriate because a genuine dispute of material fact existed about the church’s membership status. The Court further held that neither court could resolve the ecclesiastical abstention issue or the membership question on the summary judgment record. It reversed the Court of Appeals’ dismissal and remanded for further proceedings consistent with its opinion. View "Shalom Presbyterian Church of Washington v. Atlantic Korean American Presbytery" on Justia Law

The defendant operated a zoo in South Carolina and, after lions were listed as endangered under federal law in 2016, continued to purchase lion cubs from a Virginia zoo owner. In 2018 and 2019, the defendant bought several lion cubs for thousands of dollars. Based on these transactions, he was charged in Virginia with two counts of purchasing lion cubs and two counts of conspiring to sell or purchase lion cubs, all under specific provisions of the Virginia Code related to endangered species.During his trial in the Circuit Court of Frederick County, the defendant argued through motions to strike and set aside the verdicts that the statutes in question did not actually prohibit purchasing lion cubs—only selling them. The circuit court denied these motions and the jury convicted him on all counts related to purchasing and conspiracy, while acquitting him of separate animal cruelty charges. He appealed to the Court of Appeals of Virginia, which reversed his convictions for purchasing lion cubs, finding that the statute did not expressly prohibit purchases, but affirmed his convictions for conspiracy, reasoning that he could still be convicted for conspiring to sell lion cubs.On further appeal, the Supreme Court of Virginia reviewed the statutory language de novo and held that the relevant statute, Code § 29.1-564, does not prohibit purchasing or offering to purchase endangered or threatened species, only the sale or offering for sale. The Court found that the conspiracy indictments improperly permitted conviction based on conduct (purchase or offer to purchase) that was not criminalized by statute. As a result, the Supreme Court affirmed the reversal of the purchasing convictions, reversed the conspiracy convictions, and dismissed all underlying indictments, entering final judgment. View "Antle v. Commonwealth" on Justia Law

EQT Production Company and related entities owned mineral lands containing natural gas reserves in Wise County, Virginia. In 2018, EQT sold these lands to Diversified Production, LLC. The County taxed only the physical infrastructure—gas wells, pipelines, and compressors—for the 2018, 2019, and 2020 tax years, using the cost approach for valuation, but did not assess the value of the gas reserves themselves. The Taxpayers objected, arguing that this method did not reflect fair market value because the well infrastructure cannot be valued independently from the gas reserves. They also argued that the County failed to properly consider the income and market approaches to valuation. The County maintained that it was allowed to exclude the gas reserves and had properly rejected alternative valuation methods.After a trial in Wise County Circuit Court, the court found in favor of the County, holding that it had statutory discretion to value only the improvements and to exclude the reserves. The court also found that the County properly considered and rejected use of the income and market approaches. The Court of Appeals of Virginia affirmed, agreeing that because the County had imposed a license tax on gas extraction under Code § 58.1-3712, it was excused from assessing the gas reserves under Code § 58.1-3286. The Court of Appeals further held the County’s assessment was entitled to a presumption of correctness because it considered and rejected the other valuation methods.The Supreme Court of Virginia reversed. It held that, under Virginia law, imposing a license tax under Code § 58.1-3712 does not excuse the County from also assessing the fair market value of mineral lands—including gas reserves—under Code § 58.1-3286. The Court concluded the County’s assessment was incomplete and therefore plainly wrong. The judgments of the lower courts were reversed and the case was remanded. View "EQT Production Co. v. County of Wise" on Justia Law

The case concerns the process by which a proposed constitutional amendment, authorizing partisan gerrymandering of congressional districts in Virginia, was submitted to the voters. The General Assembly approved the proposed amendment during a disputed special session in October 2025, after voting in the general election for the House of Delegates had already begun. Approximately 1.3 million votes had been cast before the General Assembly’s first vote on the amendment. The General Assembly then approved the proposal again in the 2026 regular session, and the amendment was put to a popular vote, ultimately passing by a narrow margin. The new map, contingent on the amendment’s approval, would have significantly shifted the partisan balance of Virginia’s congressional delegation.The Circuit Court of Tazewell County reviewed challenges to the constitutional amendment process, focusing on whether the requirements of Article XII, Section 1 of the Virginia Constitution, which governs the procedure for amending the state constitution, were properly followed. The central issue was whether the intervening general election required by the Constitution occurred after the General Assembly’s first vote on the amendment but before the second, thus giving voters the intended opportunity to influence the process.The Supreme Court of Virginia held that the legislative process used to advance the proposed amendment violated Article XII, Section 1 of the Virginia Constitution because the first legislative vote occurred after voting in the general election had already begun. The court concluded that the “general election” includes the entire period when votes are cast, not just Election Day, and strict compliance with the constitutionally mandated procedure is required. As a result, the referendum and the amendment were declared null and void. The court affirmed that the existing, nonpartisan congressional maps remain in effect for the upcoming elections. View "Scott v. McDougle" on Justia Law

After a shooting resulted in the death of a pregnant woman with whom he had a relationship and prior drug dealings, Brian Fayne was detained by police and questioned at a station. After being advised of his Miranda rights, Fayne was interrogated for several hours and permitted to call his father, who encouraged him to seek counsel. Fayne ultimately invoked his right to counsel unequivocally during the interview. Despite this, police continued to question Fayne for over an hour, during which time a detective unaware of the invocation questioned Fayne about drug activity. The interrogation ended when the detective left the room and Fayne was left alone. Fayne then reopened communication by seeking out a detective and expressing his desire to speak further, ultimately confessing to his involvement in the shooting.The Circuit Court denied Fayne’s motion to suppress his statements, finding that although Fayne had invoked his right to counsel, he later reinitiated contact with police and knowingly and intelligently waived his right before making additional statements. The Court of Appeals of Virginia reversed, determining that the interrogation had not sufficiently ceased to allow for reinitiation under controlling precedent and that Fayne had not knowingly and intelligently waived his right to counsel.Reviewing the case, the Supreme Court of Virginia found that the initial violation of Fayne’s right to counsel did not permanently taint subsequent statements. The Court held that after the interrogation ended, Fayne, not law enforcement, reinitiated communication, and that he knowingly and intelligently waived his right to counsel under the totality of the circumstances. Therefore, the Supreme Court of Virginia reversed the judgment of the Court of Appeals and reinstated the trial court’s denial of the motion to suppress. View "Commonwealth v. Fayne" on Justia Law

William and Traci Butcher purchased a recreational vehicle for approximately $80,000, which was found to have various defects. After unsuccessful negotiations with the dealer and manufacturer, Keystone, to repurchase the vehicle, the Butchers filed suit in the Circuit Court of Hanover County, alleging violations of the Virginia Consumer Protection Act and the federal Magnuson-Moss Warranty Act. The parties eventually settled the substantive claims, with Keystone agreeing to repurchase the RV and stipulating that the Butchers were prevailing parties for purposes of attorney fees under the Magnuson-Moss Warranty Act. However, the parties did not agree on the amount of attorney fees owed.After settlement, the Butchers sought over $40,000 in attorney fees, including fees incurred litigating the fee request itself. The trial court awarded them $24,885 in attorney fees, covering time spent on the underlying claims but excluding fees related to the post-settlement litigation over the fee amount. The trial court found the excluded fees were not reasonable based on the facts and circumstances, including Keystone’s willingness to negotiate and billing practices such as block billing and lack of contemporaneous records. The trial court’s cost award was not challenged.The Court of Appeals of Virginia affirmed the trial court’s decision, concluding that the lower court did not abuse its discretion in declining to award fees for the time spent litigating the fee petition. Upon further appeal, the Supreme Court of Virginia also affirmed. It held that while attorney fees incurred litigating a fee petition (“fees on fees”) may be recoverable, they must still be reasonable and necessary under the circumstances. In this case, the court found the trial court acted within its discretion in finding the requested additional fees unreasonable. The judgment of the Court of Appeals was affirmed. View "Butcher v. General R.V. Center" on Justia Law

The defendant was stopped by police after officers saw that the registered owner of the vehicle had a suspended license. The stop occurred at night, and when the defendant rolled down his window, the officer detected the odor of alcohol. The officer observed that the defendant had glassy eyes, slurred speech, was sweating, avoided eye contact, and appeared confused about why he had been stopped. The defendant denied consuming alcohol and refused field sobriety tests. All interactions were captured on the officer’s body-worn camera. The defendant was arrested for driving under the influence, among other charges.At trial in the Circuit Court, the Commonwealth’s evidence consisted of the officer’s testimony and the body camera footage. The defendant moved to strike the evidence as insufficient, emphasizing the lack of chemical testing and absence of erratic driving. The trial court denied this motion and found the defendant guilty of driving under the influence, citing the totality of the observed circumstances. The defendant appealed, and the Court of Appeals of Virginia reversed the conviction. That court concluded that the officer’s testimony was not fully supported by the video evidence and found that alternative explanations for the defendant’s behavior, such as nervousness or tiredness, were reasonable hypotheses of innocence not excluded by the evidence.Upon review, the Supreme Court of Virginia found that the Court of Appeals had erred by reweighing the evidence and substituting its judgment for that of the trial court. The Supreme Court held that the combined circumstances—odor of alcohol, physical and behavioral observations, and immediacy of the stop—were sufficient to sustain the conviction for driving under the influence. The Court reversed the Court of Appeals and reinstated the trial court’s judgment. View "Commonwealth v. Richerson" on Justia Law

An undercover law enforcement officer conducted a controlled drug transaction with an individual inside a clothing store. Based on an affidavit alleging drug distribution, officers obtained both an arrest warrant for the individual and a search warrant for the store. When officers executed the search warrant, they ordered everyone to exit; the individual, who was the only occupant, was detained and handcuffed. Officers read the search warrant and affidavit to him but did not provide physical copies, reasoning that the store was not a residence and he was not its owner. The subsequent search uncovered marijuana and firearms, leading to additional charges.In the Circuit Court, the individual moved to suppress the evidence, arguing that Code § 19.2-56(B) required officers to provide a copy of the search warrant and affidavit to any occupant of a place being searched, not just for residences. The circuit court interpreted the statute as applying to all search warrants, but held that the individual was not entitled to copies because he was no longer an occupant after being arrested. The individual entered a conditional guilty plea to preserve his right to appeal. The Court of Appeals of Virginia affirmed, but on different reasoning. It concluded that the statutory requirement to provide copies applied only to search warrants for a “place of abode,” not commercial premises.The Supreme Court of Virginia reviewed the case to determine whether the statutory requirements of Code § 19.2-56(B) apply solely to search warrants for residences or to all premises. The Court held that the entirety of Code § 19.2-56(B) applies only to search warrants for a “place of abode.” Because the search occurred in a commercial establishment, the officers were not required to provide a copy of the warrant or affidavit. The Supreme Court of Virginia affirmed the judgment of the Court of Appeals. View "Blow v. Commonwealth" on Justia Law

A police officer initiated a late-night traffic stop after observing a vehicle making frequent lane changes and driving well below the speed limit. The officer determined that the registered owner of the vehicle had a suspended license and that the driver, Nafeesa Rausham Knight-Walker, resembled the owner’s photo. Upon stopping the vehicle, the officer confirmed that Knight-Walker was driving with a suspended license and that neither she nor her passenger could lawfully drive the car away. During the encounter, the officer asked Knight-Walker about weapons and drugs in the vehicle, questions which took approximately twelve seconds. Knight-Walker consented to a search of her person and her purse, and the officer subsequently found drug paraphernalia in the vehicle. She was later charged with possession of controlled paraphernalia.The Circuit Court for the City of Newport News denied Knight-Walker’s motion to suppress the evidence, finding that the officer did not unlawfully prolong the stop because the mission of the stop was not complete: Knight-Walker could not drive the car away, and it was reasonable for the officer to remain at the scene. The court also found her consent to search was voluntary. Knight-Walker entered a conditional guilty plea and appealed. The Court of Appeals of Virginia reversed, holding that the officer’s questioning extended the stop beyond its permissible duration under the Fourth Amendment, citing Rodriguez v. United States, and suppressed the evidence.The Supreme Court of Virginia reviewed the case and reversed the judgment of the Court of Appeals. The court held that, under the totality of the circumstances, the officer did not impermissibly extend the traffic stop. The brief questioning about weapons and drugs was deemed reasonable and related to officer safety, especially since the stop was ongoing and the officer needed to control the scene until a licensed driver arrived. The court also affirmed that Knight-Walker’s consent to search was voluntary and not tainted by an unlawful detention. Final judgment was entered for the Commonwealth. View "Commonwealth v. Knight-Walker" on Justia Law